| Comment Number: | 522418-10193 |
| Received: | 7/15/2006 10:13:06 PM |
| Organization: | Xango |
| Commenter: | Stacy Cizek |
| State: | IA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sirs and Madams, I am writing about the Business Opportunity Rule, R511993. Although I believe I understand the motivation behind the proposed rule change, there are elements that greatly concern me. The References portion of the Rule concerns me from a confidentiality standpoint. I am a Registered Dental Hygienist in Iowa, and HIPPA requires that we do not disclose any medical information about patients, but this references rule seems to be a breech of privacy for our Xango customers. I don't care to have anyone know if I have any health conditions or use any medications or natural remedies and I don't believe that we should have to disclose the "10 nearest existing sales people" to our prospective clients. These existing sales people are also Xango users who are taking the product not only for preventive reasons, but also to treat a variety of health conditions. The possibility of identity theft also is of great concern. I also have great concern about the seven day waiting period. The people that are looking into this business opportunity are wanting to better their lifestyle, and oftentimes are very excited about the business opportunity for the first 48 hours or so after being introduced to the business plan. Often times, if you do not have contact with these prospects within the first critical 48 hours, their excitement level drops and they are not sure about the business anymore. This is unfortunate for them as I have seen several business builders get a substantial start on building their organizations in the first 48 hours due to the sheer excitement of their new business venture. In my opinion, this waiting period would hurt legitimate business organizations. The waiting period is very impractical, will cause record keeping nightmares, and also unnecessary delays. After all, in the case of Xango, these new business builders are trying to buy Mangosteen juice, not purchase a firearm. Having a small business which I operate in my spare time away from my family and my full-time employment, I will be severely challenged by any Rule that requires a waiting period and a lot more paperwork. I appreciate what the FTC is trying to do, but I sincerely hope Business Opportunity Rule R511993 does not become law. Sincerely, Stacy Cizek